Privacy Policy

Last updated: 26th April, 2024

Introduction and General Terms

Evening Tiger N.V. (the “Company” or “We”; “Our” and “Us” shall be interpreted accordingly) is committed to protecting and respecting your privacy and maintaining the confidence and trust of Our partners.

The Company processes Personal Data (“Personal Data” or “Data” ) in accordance with this Privacy Notice, and in accordance with all applicable laws, including, where applicable, the General Data Protection Regulation (2016/679) (“GDPR”) and the applicable national data protection laws. Any capitalised term not defined herein, shall have the same meaning assigned to it in the Terms and Conditions applicable to the Sisu Partners’ Affiliate Programme available here.

Reference in this Privacy Notice to “Personal Data” means any information that can be used to directly or indirectly uniquely identify, contact or locate You as a private individual.

This Privacy Notice explains how and why your personal information is collected and used through the Affiliate Programme, use of Our website www.sisu.partners and all variants of it, including Our mobile apps and mobile websites, if any (the “Website”), and how it is kept secure.

The Privacy Notice (hereinafter the “Notice”) applies to any Affiliate, prospective Affiliates or other user or visitor to Our Website. The term “Services” shall refer to the Company’s operations in managing the Affiliate Programme.

Data Controller

If you are an individual who is a resident of the European Union (EU) or the European Economic Area (EEA), the Company assumes the role of the controller for the Personal Data you provide, and that the said controller collects and processes concerning Our Services.

As someone accessing or utilizing Our Services, the acquisition, handling, and sharing of your Personal Data are governed by this Notice, inclusive of Our Cookie Policy, and any subsequent revisions.

Changes to this Privacy Notice

The Company reserves the right to amend this Notice, and in the event of significant alterations, We will furnish notification through Our Services or alternative channels, affording you the chance to scrutinize the modifications before their implementation. Should you dissent with any amendments, you have the option to terminate your Affiliate Account in accordance with the aforementioned Terms and Conditions.

By continuing to use Our Services subsequent to the publication or dispatch of a notice regarding alterations to this Notice, you acknowledge that the gathering, utilization, and dissemination of your Personal Data are contingent upon the revised Privacy Notice.

Getting In Touch With Us

There are various ways you can contact us.

For general queries do not hesitate to get in touch with Our team via email [email protected].

If you have any specific questions regarding your personal information or how We use it, please contact Us on [email protected].

Types of Information We Collect & Process

We gather Personal Data as part of your interactions with Us and utilization of Our Services. The legal basis for processing in this context is of a contractual nature, i.e. it is information that We require in order for you to be able to partner with Us, participate in the Affiliate Programme, and/or make use of Our Services, or apply to make use thereof. Personal Data may be provided on different occasions and at different periods in the lifecycle of Our relationship with you.

Information you may be required to provide to Us upon submitting an application to become an Affiliate or thereafter once a person becomes an Affiliate as directed by Our procedures (the below may also apply with respect to representatives of legal entities when the Affiliate is a legal entity):

Your personal details, such as your name, email address, telephone or mobile number;
Photographic identification and proof of address documents (to carry out KYC or customer due diligence processes);
Payment details;
Proof of ownership of accounts used to receive settlement of funds;
Further information relating to the personal background of the person, such as residential address, identification number, gender, date of birth, and other data required to satisfactorily comply with applicable laws, rules, regulations and internal policies.

Through your use of the Services:

Details on your interaction with Our products;
Data regarding your online browsing patterns on the Website, mobile apps, and other digital content—refer to Our Cookie Policy for comprehensive information;
Particulars about the devices utilized to access Our Services, encompassing device identifiers, proxy servers, operating systems, IP addresses, and browser types;
Upon entering or leaving Our Services, We receive the URLs of both the preceding and subsequent websites you visit. In the case of mobile device usage, your device transmits data about your location based on phone settings, with an opt-in request for GPS or other tools to ascertain precise location.
Recording of phone calls may occur for purposes such as verifying accurate execution of instructions, resolving queries, meeting regulatory requirements, enhancing service quality, staff training, or identifying and preventing fraud or other unlawful activities.
Information voluntarily shared with Us or publicly disclosed, such as through social media channels.
The servers hosting Our websites and applications may retain logs or records of your server requests (web addresses opened, browsers and devices used). These logs and data serve strictly technical purposes, particularly for investigating potential security incidents.

Other sources of personal data:

Where We provide personalised services, We may use third party data about you, for example, your Twitter or Facebook feeds, to get to know you better and to provide more effective personalisation and to be able to ensure that Our relationship with You is being undertaken in line with the applicable Terms and Conditions;
Data received from Our business partners and from other organisations, such as specialist companies providing the affiliate tracking software, verification services, credit reference agencies, and fraud prevention tools;
Publicly available sources, like postcode lookup.

Should you furnish Us with personal information concerning someone else, it is imperative to obtain their explicit permission. In instances where you provide information about someone else or someone else reveals information about you, this data may be incorporated into the existing personal information We hold, and its utilization will align with the descriptions outlined in this Privacy Notice. It is important to note that this list of collected personal data types by the Company is not exhaustive, and additional information may be solicited when deemed fair and necessary by the Company.

Basis For Collecting & Processing Personal Data

We acknowledge the trust and confidence bestowed upon Us by Our partners.

Primary among Our responsibilities is the collection of your information, integral to fulfilling Our obligations to You, where applicable. Furthermore, your data serves the purpose of personalizing and enhancing your experience with Our Services, and We may intermittently reach out with crucial information pertaining to your account or vital updates concerning Our Website. On occasions, it becomes necessary to collect and utilize your information to adhere to legal requirements. Rest assured, We undertake the collection and processing of Personal Data about you solely when a legal basis is established, relying on different bases for distinct processing activities.

Contractually

This legal basis of processing exists when it is necessary for the performance of a contract to which you are a party. Our Terms and Conditions, which, in the case of Affiliates, you have accepted at registration, set out the terms of the contract and the Services We provide:

To make Our Services available to you as part of the contract

to manage the Affiliate Programme;
to verify Your identity, to communicate with You, including providing updates and responding to inquiries.
to analyze and improve the performance and functionality of Our Affiliate platform.
to comply with applicable laws and regulations.

Under Legitimate Interest

Under this legal basis, processing your data for the outlined purposes is deemed necessary, except in cases where Our interests are superseded by the interests, rights, or freedoms of the individuals affected, including yourself. To assess the viability of processing your data on this basis, We will take into account various factors. These include the information communicated to you at the time of data provision, your expectations regarding data processing, the nature of the data, and the potential impact of the processing on you.

To improve Our Services and products

to provide you with the most user-friendly online navigation experience;
for analysis and research purposes so that We may improve the Services offered by the Company;
testing new systems, functions and performing upgrades to existing systems;
evaluating the effectiveness of marketing and for market research and training;

To contact and interact with you

Contact you about Our Services and Affiliate Programme, for example by phone, email, post or social media;
To manage promotions and competitions you choose to enter;
Invite you to take part in and manage surveys, questionnaires and other market research activities carried out by the Company;
Respond to your queries and complaints.

To make your experience with Us safer and more enjoyable

to prevent or detect any activities conducted in breach of Our Terms and Conditions;
to ensure network and information security.

Under a legal obligation

Processing Personal Data when it is necessary in order to comply with mandatory legal obligations to which We are subject to under European Union legislation or local laws in other jurisdictions:

Determining Your Location: To ascertain your access point to the Services in case this is relevant for the purpose of compliance with applicable law and/or the applicable Terms and Conditions. This is without prejudice to any obligations of Affiliates in line with the said applicable Terms and Conditions.

Ensuring Service Eligibility: Verifying that Our Services are extended solely to eligible persons in line with the Terms and Conditions.

Crime Detection and Prevention: Where applicable, employing data for the purposes of detecting and preventing criminal activities.

Anti-Fraud Measures: Conducting necessary anti-fraud checks to safeguard against fraudulent activities.

Accuracy of Personal Information: Regularly verifying the accuracy of your personal information to fulfill legal obligations. This may involve periodic re-verification of data, including disclosure to and receipt from third-party identity and address verification service providers. If you believe any of the personal data We hold about you is inaccurate, please contact Us on [email protected].

Sharing Your Personal Information

The Company forms part of a group of companies (“Sisu Group”). We do not disclose your personal information to external third parties beyond the Sisu Group for marketing purposes. However, certain situations necessitate the sharing of your Personal Data with other entities within the Sisu Group, third-party service providers acting on Our behalf, and additional third parties to fulfill legal obligations. Even in instances of sharing, We guarantee that your personal information will exclusively be utilized for the purposes specified in this Privacy Notice.

With other companies within Sisu Group

The Personal Data We gather may be shared with other companies within the Sisu Group for the following objectives:

Handling of payments: Carrying out settlements to you and receiving top-ups from you through payment providers
Fulfilling contractual obligations: An intrinsic part of the Affiliate Programme is the link to the gaming services. These are provided by the relevant group companies that are licensed for this purpose.
Providing Products and Services: Furnishing you with products and Services and keeping you informed about significant alterations or advancements in the features and operation of those products and Services.
Handling Enquiries and Complaints: Addressing your queries and complaints effectively.
Administering Offers, Competitions, and Promotions: Managing and overseeing offers, competitions, and promotional activities.
Facilitating Secure Access: Ensuring secure access to online platforms.
Record Accuracy Improvement: Updating, consolidating, and enhancing the accuracy of Our records.
Transactional Analysis: Undertaking analysis related to transactions.
Crime Detection, Prevention, and Prosecution: Contributing to crime detection, prevention, and prosecution efforts, while complying with regulatory requirements.

With third parties

We may disclose personal data to third parties in the following scenarios:

Providing Products and Services: Sharing information to provide you with products and Services and keeping you informed about significant changes or developments in their features and operation.
Legal Compliance: Disclosing information when mandated by regulatory bodies or legal provisions stipulated in the applicable law.
Regulatory Requests: Sharing information to comply with requests from authorities either directly to Us or to payment providers who are also subject to regulatory oversight.
Legal Rights: Sharing data to establish, exercise, or defend Our legal rights.
Fraud Detection and Control: Transferring personal data, including to address verification system service providers, payment service providers, and financial institutions, for fraud detection and control purposes.
Service Providers: Collaborating with service providers to facilitate the provision of Our Services, including technology services, data storage, processing payments, due diligence collection and vetting services, customer support tools, and relevant online advertising.
Auditors: Sharing information with external auditors conducting independent checks for Our accreditations or for the purpose of complying with statutory obligations.
Business Sale or Transfer: Disclosing data to organizations We sell or transfer any of Our businesses or rights and obligations under agreements with you. In such cases, the receiving organization can use your personal data similarly to Us.
Successors in Title: Sharing data with any successors in title to Our business.
Network and Information Security: Sharing information with security communities to ensure network and information security.

It should be noted that in some jurisdictions other than the EEA, sharing of Personal Data with third party providers (such as payment providers) may be subject to consent. By using such payment methods, you grant your consent to Us to share the required Personal Data specifically for the relevant purpose.

Transferring Your Data

The Personal Data We collect from you might be transferred to and stored in a location outside the European Economic Area (“EEA”). It could also be processed by entities operating outside the EEA on Our behalf or for one of Our service providers. For example, the computer servers hosting a website may be situated outside the EEA, which is common in the global internet environment. The destination where your personal information is held may offer a level of data protection different from that in the EEA. To ensure the security of your personal information during such transfers, We will take all reasonable measures to uphold an appropriate level of protection in accordance with this Notice.

If you are a resident of the EEA, any transfer of your personal information to a location outside the EEA will adhere to one of the following:

Standard Contractual Clauses: We may rely on the Standard Contractual Clauses adopted by the European Commission or a relevant data protection authority.
Adequacy Decision: The transfer may be based on an adequacy decision from the European Commission, confirming that the third country provides sufficient protection for your personal information.
Consent or Legal Basis: Your consent or another legal basis entitling Us to make the transfer.

Data Retention

We will retain your information only for the duration necessary to fulfill the purposes for which it was collected.

While you are an active Affiliate, We need to keep your information to meet legal and contractual obligations. Even after discontinuing the use of Our Services or following rejection of your application to become an Affiliate, Your Personal Data may be retained for a specific period for various reasons:

Legal Compliance: To comply with legal obligations under EU/local laws, such as anti-money laundering regulations or licensing requirements.
Legal Claims: To establish or defend against potential legal claims, such as negligence claims, that might be made against us.
Contractual Obligations: To comply with contractual obligations and rights related to the information involved.
Legitimate Interests: Pursuant to Our legitimate interests, as determined through balancing tests.
Guidelines from Data Protection Authorities: To comply with guidelines issued by relevant data protection authorities.

The retention of your Personal Data is contingent on the active status of your Affiliate Account and the requirements of applicable law or identified legitimate interests. Additionally, based on Our legitimate interest and internal risk management, your Personal Data may be retained for up to 10 years.

In the event of Affiliate Account Closure:

After closing your Affiliate Account, We retain your Personal Data if necessary for legal or contractual obligations, regulatory requirements, dispute resolution, security maintenance, fraud prevention, and abuse prevention.

Personal Data will be deleted five years after the closure of your Affiliate Account, considering compliance with applicable laws, due diligence policies, fraud prevention and legitimate interests. In limited cases, contractual obligations might require Us to retain Personal Data for a longer period, which in no case shall exceed 10 years.

Your Rights as a Data Subject

We acknowledge that, by law and subject to certain conditions, you have several rights concerning the Personal Data We hold about you. To exercise these rights, you should contact Us on [email protected]. These rights include:

Right to Access, Amend, and Erase: You have the right to access, amend, and erase the personal information We hold about you.

Right to Object: You can object to the processing of your data based on your specific situation.

Right to Withdraw Consent: If We rely on your consent for processing your personal information, you have the right to withdraw it at any time.

Right to Data Portability: You have the right to receive personal information you provided to Us in a commonly used machine-readable format.

Rights Related to Automated Decision-Making and Profiling: You have certain rights in situations involving automated decision-making and profiling.

Right to Restrict Processing: You can ask Us to restrict the processing of your personal information under certain circumstances.

If you have concerns about how We process your information, you also have the right to complain to the applicable data protection authority.

Right to Access, Amend, and Erase:

You can request a copy of the personal information We hold about you.
You can request the correction or removal of information that is incorrect or has changed.

You can ask Us to erase personal information We hold about you (‘the right to be forgotten’) under specific circumstances. This includes when:

the information is no longer necessary in relation to the purpose for which it was collected;
if you previously gave consent to the use of your Personal Data, but decide to withdraw it and We cannot justify another legal ground for using it under data protection law;
We process your information based on Our legitimate interests and We cannot demonstrate overriding legitimate grounds to continue processing the information;
We do not have a lawful ground under data protection law to process your information;
the data has to be erased to comply with a legal requirement.

Right to Restrict Processing:

You can ask Us to restrict the processing of your personal information under certain circumstances. This right is available to you when:

you dispute the accuracy of the personal information (while We verify matters);
the processing is unlawful, and you object to the erasure of the information and request that We restrict processing instead;
We no longer need the data, but you require it to establish, exercise or defend a legal claim; and
We process your information for Our legitimate business interests but you object and while We verify the grounds for continued processing.

Right to Object:

You can object to the processing of your personal information based on legitimate interests, research and statistical purposes, or direct marketing.

Right to Withdraw Consent:

If We rely on your consent for processing your personal information, you can withdraw it at any time by writing to [email protected].

Right to Data Portability:

You have the right to receive personal information you provide to Us in a ‘commonly used machine-readable format’.

Rights Related to Automated Decision-Making, Including Profiling:

You have the right not to be subject to a decision, including profiling, based solely on automated processing when it has a legal or similarly significant effect.

We may use automated decision-making in the following situations:

tailoring products and services – We may place you in groups with similar customers (segments) to study and learn about preferences and your needs, and offer a more tailored experience for you;
detecting fraud – We use your personal information to help decide and detect if your account may be used for fraud or money-laundering. If We think there is a risk of fraud, We may block or suspend the account;
opening an Affiliate Account – when you open an account with Us, We check that the product or Service is relevant for you, based on what We know. We also check that you meet the conditions needed to open the account. This may include checking age, residency, nationality or financial position.

Please note that the right does not apply when the processing is:

necessary for entering into or for the performance of a contract with you; or
when it is authorised by law; or
when it is based on your explicit consent which has not been withdrawn.

We may retain your Personal Data after account closure for legal obligations, regulatory requirements, dispute resolution, security maintenance, fraud prevention, and abuse prevention. Personal Data will be deleted in line with the aforementioned data retention periods.

Requests concerning the mentioned rights must be addressed in writing to [email protected]. We will respond within thirty days, with a possible extension of sixty days based on the complexity of the request and pending requests. If your request does not comply with data protection law requirements, We reserve the right to impose a reasonable fee or reject your request.

Security

We have implemented the necessary technical and organizational measures to secure the processing of your Personal Data, ensuring confidentiality and data integrity.

To safeguard your Personal Data, the Company adheres to stringent security standards. Our systems undergo regular monitoring for potential vulnerabilities and attacks, including penetration testing. Our employees receive training from qualified professionals, and We employ comprehensive security measures for Our network and infrastructure.

Despite these efforts, We cannot guarantee the absolute security of information transmitted to Us. While We have in place physical, technical, and managerial safeguards, there is always a risk that data may be accessed, disclosed, altered, or destroyed due to breaches in Our security measures.